OISD PETROLEUM AND NATURAL GAS (SAFETY IN OFFSHORE OPERATIONS) RULES, 2006.

OISDOISD

PETROLEUM AND NATURAL GAS

(SAFETY IN OFFSHORE OPERATIONS) RULES, 2006

OISDOISD

Decisions of meeting chaired by Secretary- P&NG on 16.09.05

• OISD assigned the safety of all oil & gas installations including offshore & PSC.

• P&NG rules under ORDA to be amended accordingly

BACKGROUND

OISDOISD

• Second meeting held by Secretary-P&NG on 07.03.06

• Draft Zero of offshore safety rules presented

• The Rules circulated to concerned ministries for comments

BACKGROUND

OISDOISD

• Legal consultant hired by OISD • Vetted by PSA Norway, MMS USA • Comments sought from Ministry of Labour,

Shipping, MOEF, MEA and MOD• Comments sought from operating

companies• After incorporation of suggestions & final

legal drafting the rules will be sent to Law Ministry

METHODOLOGY OF FRAMING THE RULES

OISDOISD

• Use of simple language in place of legal

jargon to the extent possible

• Control by means of goal setting requirements

• Detailed and specific rules may dilute the operator’s perception of responsibility towards safety

MAIN PRINCIPLES

OISDOISD

• The operator i.e. user of facility must

identify the problem areas and work out solutions

• Responsibility towards safety lies with the operator

• The operator is responsible for compliance of rules by his contractors

MAIN PRINCIPLES

OISDOISD

• Risk shall be identified in a systematic

manner and shall be reduced to an acceptable level (ALARP)

• Risk acceptance criterion to be set by the operator for his facility

• Acceptance criterion shall be limited to high level expressions of risk (Global risk estimates)

MAIN PRINCIPLES ….contd

OISDOISD

• Consent for operation required to ensure compliance

• Safety issues addressed from design stage to abandonment

• Probability reducing measures have been given priority over consequence reducing measures


OISDOISD

Concept of barriers:

1. The operator shall establish strategies and principles so that the barriers are ensured for the lifespan of the facility

2. Barrier elements can be physical, organisational or operational

3. It shall be known at all times what barriers are non-functional or impaired


OISDOISD

I Preliminary

II Principles Related to Health, Safety and

Environment

III Information and Records

IV Consent and Intimation

V Risk Management

VI Safety Management

CHAPTERS

OISDOISD

VII Health and Welfare Measures

VIII Transport and Stay

IX Safety Zones

X Emergency Response System

XI Facilities - Design

XII Facilities – Physical Barriers

XIII Operational Pre-requisites

CHAPTERS

OISDOISD

XIV Planning and Conduct of Activities

XV Working Environment FactorsXVI Drilling and Well ActivitiesXVII MaintenanceXVIII Specific OperationsXIX Marine Facilities and OperationsXX EnvironmentXXI Miscellaneous

CHAPTERS

OISDOISD

Comments OISD response

1. Generic & not specific

2. Competent authority –OISD

3. Penal provision

4. Definition of operator

• Goal setting approach

• Roles, respo. etc shall be notified

• As per MZI & ORDA act

• Operator refers to company

Hardy Exploration & Prod(India) Inc

OISDOISD


5. Compliance to class & flag state requirements

6. SOLAS, MARPOL

7. Too many Schedules

8. Periodic reports

• OMR (DGMS)

• Rule 30 & Rule 1(3)

• Rule 1(3) & 1(4)

• Considered optimum• Noted- will be

reviewed• Applies to onland &

territorial waters

Hardy Exploration & Prod(India) Inc

OISDOISD


1. Acco.capacity not to exceed

2. Survival suits & Life jackets

3. Periodic audit of examination of

emer.resp.eqpt4. To include all

contractors for PPE use

• Rule 50-No change

• Implied in rule 77

• Rule 37

• Noted –will be reviewed

Schlumberger Asia Services Ltd

OISDOISD


5. Special baskets, certification & night transfer

6. To include lifting eqpt certification

7. Trained crane operators

8. Hygiene concerns9. Accounting of

persons

• Rule 169(4) & Rule 175(2)

• Rule 169(1) read with rule 37

• Implied in Rule 129

• Rule 42• Rule 49

Schlumberger Asia Services Ltd

OISDOISD


1. Safety agency should be independent of the administrative ministry

Therefore Regulation of safety should be by agency other than OISD

-----

ONGC

OISDOISD


2. Agree to consent to operate, how ever time period be increased to 2 years from 180 days for existing installations

3. Consent for Combined opn’s not feasible

• Increased to 1 year (draft 2). Will be further reviewed

• Changed to Intimation (Draft2)

ONGC

OISDOISD


4. One time combined operations consent for specific cases

5. Certificate of Fitness

a. For existing inst. time period to be extended

b. Reputed third party

• Noted-will be reviewed

• Increased to one year (draft 2).will be further reviewed

• Operator to decide as safety is his responsibility

ONGC

OISDOISD


6. Dual regulatory regimes

a. OISD & MOEF

b. OISD & DGCA

c. OISD & DG shipping

d. OISD & DGMS

• Clarified in Draft 2 • No overlap• No overlap• Overlap in

territorial waters only

ONGC

OISDOISD


7. Legislation should be dynamically linked to global industry recognised standards like API, IMCA, NFPA, SOLAS etc

ONGC

• Shall be done wherever considered appropriate

OISDOISD


1. Combined operation definition to include construction also

2. Launchers and receivers should be included in offshore facilities rather than pipeline

NIKO RESOURCES

• Noted –will be included

• No change

OISDOISD


3. Risers to be considered up to last isolation valve in the pipeline

4. Notice of accident- to add in 12(e) whereby safety of a person or facilities likely to be endangered

NIKO RESOURCES

• No change


OISDOISD


5. Barriers shall be commensurate with the probability and consequence of the incident

6. Criteria for certificate of fitness must be defined

NIKO RESOURCES

• Rule 23(1)

• Fit for the purpose as per rule 30(1)

OISDOISD


7. Delete maintenance of communication equipment from responsibility of desig person

8. Include inspection with maintenance in rule no 107(2) on pipeline

NIKO RESOURCES

• Noted-will be deleted

• Noted- will be included

OISDOISD


1. Operator in different areas- contractor or company man

2. Operator to pay cost incurred on instrumentation

3. OIM is company or contractor man

• As per definition- drilling contractor is operator

• Clause will be reviewed

• Contractor man in case of a drilling contractor

Transocean Offshore International

OISDOISD


4. Onboard Safety Officer - not in existing contracts

5. Safety committee meeting participation and acceptance

6. Equivalent of BIS IS: 10500 for potable water

• Will follow once rules come into force

• Implied in Rule 34

• Noted- will be reviewed


OISDOISD


7. Helicopter coverage at all times

8. Standby vessel to be shared by maximum two installations

9. Survival suits not required

• Not covered in rules

• No change in rule 63

• Noted- will be changed


OISDOISD


10.Drilling and well activities chapter to be replaced by IADC guidelines

11.BOP etc to be overhauled as per API

12.Communications during Lifting operation

• No change




OISDOISD


13. Identification of rough weather conditions by company or contractor

• Contractor is operator as per definition in case of hired rig


OISDOISD


1. Regulatory expectation of word competence

2. List of monitoring parameters

3. Metocean data

• In absence of definition, dictionary meaning to be followed

• Operator to decide

• Clause will be reviewed

BG India

OISDOISD


4. Notice of accident –personal injuries & asset damage

5. Decommissioning guidelines

6. Application for consent


Rule 12 f• Noted –will be

provided

• Rule is explicit

BG India

OISDOISD


7. Material changes

8. ALARP – Rule 22(5) compliance

9. Trainings for offshore going employees to be specified

BG India

• Significant changes

• Yes for rule 22

• Rule 129

OISDOISD


10.Certificate of fitness

11.Safety officer and safety committee rules to be deleted

BG India

• Installation to be fit for the purpose as per rule 30(1)

• No change

OISDOISD


12.The competent person should be trained as HLO

13.Safety Zone to be increased

14.Safety zone area must be avoided for navigation

BG India

• Rule 129

• No change for time being

• Rule 52(2)

OISDOISD


15.Monitoring of safety zone –visual or electronically

16.Standby vessel for each field in place of installation

17.Survival suit not required

BG India


• No change

• Noted –will be changed

OISDOISD


18.Damage to subsea facilities by activities with high probability of occurance

19.Probability of occurance of single mistakes should be considered

BG India


• Implied in 82(c)

OISDOISD


20.Two independent communication facilities may not be available in temporary manned facility

21.One valve of christmas tree to be remotely operated may be dropped

BG India

• Noted-will be made compulsory only for manned facilities

• No change

OISDOISD


22.Guidance document will be required for lighting & radiation

23.Add- or pipeline systems shall have sufficient protection to mitigate the risk from these operations

BG India

• Noted-will be provided

subsequently

• Noted-will be modified

OISDOISD


24.Rule no 121 on Fire water supply includes unattended platforms

25. In some cases living qtr is a bridge & fire division as per rules 115/116 is not required

BG India

• Yes

• Noted-rule 116 will be modified

OISDOISD


26.Minimal offshore facilities such as well head platforms may be separated from main facilities with regard to fire and gas detection system

BG India

• No change

OISDOISD


27.Automatic activation of deluge in case of gas detection may be hazardous

28.Rule 149(4)- if a barrier fails no other activity shall take place in the well than those to restore the barrier

BG India


• It applies to all well operations

OISDOISD


29.Rule 153(4) applies to those well interventions before permanent tree is installed

30.Eqpt. & procedure for detecting & assessing actions of vessels intruding in the safety zone

BG India

• Yes

• Operator is free to decide

OISDOISD


1. Who sets the acceptance criterion

2. Accidental loads – not possible to quantify all

Premier Oil

• The operator as per rule 28(7)

• Agreed but these are required to be determined to best possible accuracy

OISDOISD


3. By giving consent competent authority accepts responsibility for the design, operation and ER of the operator

4. Security of installation should be added to rule 3

Premier Oil

• Responsibility is covered in rule 7(1)

• Covered by other existing rules of GOI

OISDOISD


5. There is no definition of competence in rule 4(2)

6. Rule 6 -offshore clinic can not offer curative services from all ailments

Premier Oil

• In absence of definition, dictionary meaning shall be followed

• Routine curative services only

OISDOISD


7. Not possible for future employees to contribute to HSE matters in design of a facility

8. Information and records required are not defined

Premier Oil

• Obviously

• Not intended to make rules prescriptive

OISDOISD


9. There should be some cut off time for maintenance of information & records

10.Rule 10 is to allow operation of new installation

Premier Oil

• Rule 9(5)• Agencies as per rule 8

• It is an intimation only by the operator

OISDOISD


11.Time period of 90 days is unrealistic for small unmanned installations design review

12.Schedule II should not include design information of Sch I

Premier Oil


• No change

OISDOISD


13.For a drilling rig, total lead time of 5 months to drill a well is not viable

14. In case of combined operations –Sch IV/V and Sch VI are to be submitted

Premier Oil


• Yes

OISDOISD


15.Rule 22(4) & (5) appear contradictory

16.Rule 23- all concerned may include onshore support persons

17.Rule 28- SMS should refer to OHSAS 18001

Premier Oil

• Not contradictory but complimentary

• Yes


OISDOISD


18.National performance standards w.r.t objectives

19.Rule 28(6)-accordance between operator and other participant requirements

Premier Oil

• Will be considered at a later time

• Other participant means his contractors and service providers

OISDOISD


20.Rule 28(7)-setting of acceptance criteria

21.Rule 30-certificate of fitness

22.Rule 31- information requirement is wide ranging

Premier Oil

• Operator to decide• Competent authority

may stipulate on case to case basis

• Installation to be fit for purpose as per rule 30(1)

• As required for planning & conduct of petroleum activities

OISDOISD


23.Rule 39-authorities to have training before going offshore

24.Rule 46-Maximum no of days offshore in one tour

25.Additional persons onboard

Premier Oil



• Rule 50(3)

OISDOISD


26.Rule 52- Intrusion into safety zone

27.Rule 59-assessment of vessel traffic and announcement of safety zone

28.Rule 64(2)- coordinat-ion of em. prep. In handling of situations

Premier Oil


• Not covered• Rule 59(2)

• No change

OISDOISD


29.Rule 67-operator to make his best endeavours

30.Rule 80-unacceptable risk may be defined

31.Rule 82(b)-risk reduced to as low as practically possible

Premier Oil

• Implied


• Noted-will be changed to ALARP

OISDOISD


32.Rule 86(1)a implies failsafe

33.Rule 87-suggests quantitative limits for loads

34.Rule 93-monitoring equipment for verification schemes

Premier Oil

• Implies limited possibility of human error


• No change

OISDOISD


35.Rule 103- weather limit for basket transfer

36.Rule 129(4)-necessary trainings

37.Rule 138-permit to work

Premier Oil

• Rule 175(2)

• Goal based approach


OISDOISD


38.Rule 162-classification system for identifying maintenance regimes

39.Rule 164- extent of inspection not defined

Premier Oil

• Implied in rule 162


OISDOISD


1. Clearance /time schedule

2. Combined ops. to include time comp.

3. Mapping results-not clear

Cairn Energy

Noted-will be reviewed

Noted- will be incorporated

It is quite explicit

OISDOISD


4. Reporting of accidents to be streamlined

5. Off-site Emergency Response Plan

6. Identification of

Off-shore Installations

Cairn Energy

As per regulatory frame work

Operator will have to take lead in its preparation

No change

OISDOISD


7. OIM, Safety Officer and Safety Committee for Offshore facilities

8. Supervisory Authority

9. ‘Qualified Medical person’ to include paramedics also

Cairn Energy

Offshore facilities here imply manned facilities and associated unmanned facilities

No Change

Noted – will be reviewed

OISDOISD


10.Competent person for controlling helideck operation

11.Annual probability – rule 82 (3) – less than

12.Status of safety devices- not clear

Cairn Energy

It would be on manned facilities

No change

Status means ops./non ops./bypassed

OISDOISD


13. Instrumentation for monitoring structural integrity

14. Two independent warning methods to shore

15. Launchers and receivers- automated fail safe mechanism would be expensive/ difficult retrofitting

Cairn Energy

No change

Shall be for permanently manned facilities

Noted – will be reviewed

OISDOISD


16. Warning system where gas released as extinguishing medium

17. Open drain system Vs closed drain system

Cairn Energy

Noted-will be incorporated

No change

OISDOISD


18. Pipeline monitoring within two years of installation-to be reviewed

19. Form-III - particulars of the deceased to be included

Cairn Energy

Rule 164 (5) mentions (first) inspection and not monitoring

Noted for incorporation

OISDOISD


20.Discharge point for produced water-marine out fall

21.Treatment system for collecting and treating open drainage in prod. plants

Cairn Energy

Implied in rule 106(4)

Noted- will be reviewed

OISDOISD


Cairn Energy

22. Pre-surveys- safe distances from environmental sensitive receptors

23. Consent to operate under air and water Acts

Implied in rule-127

Covered in rule

1 (4)

OISDOISD


It is in domain of MOEF

Covered under rule 1(4)-however will be reviewed for inclusion under rule 178

Cairn Energy

24. Offshore environmental monitoring protocol development

25. Off-shore disposal of drill cuttings and drilling mud

OISDOISD


It is explicit

There is no overlapping

Draft definition to be retained

IOCL

1. Rule-30 Verification of fitness

2. Rule 7(3)-Overlapping of responsibilities of operator and licensees/lessees

3. Definition of Competent person to be as per Petroleum Rules

OISDOISD


1. Chapter –I

2. Chapter –II

3. Chapter –III

para 1

para 2

Reliance

• Under consideration of Govt


• Operator to decide• Noted-will be reviewed

OISDOISD


4. Chapter –IV

para 1

para 2

para 3

para 4

para 5

para 6

Reliance

• Goal based approach• Relevant rules• It is one time consent• Noted-will be reviewed• Noted-will be reviewed• One time consent

OISDOISD


5. Chapter-VIpara 1para 2

6. Chapter –VII7. Chapter-VIII

para 1para 2

8. Chapter IX

Reliance

• Operator to decide• No change• Goal based approach

• Rule 92• No change• Beyond scope of

these rules

OISDOISD


9. Chapter-Xpara 1para 2para 3

10.Chapter –XI

11.Chapter-XII

Reliance

• Goal based approach • No change• No change• Covered & implied in

rule 79• Noted-will be reviewed

OISDOISD


12.Chapter-XV

13.Chapter –XVI

14.Chapter-XX

Reliance

• Goal based approach • Rule 1(4)• No frequency

mentioned• Beyond scope of

these rules

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OISD PETROLEUM AND NATURAL GAS (SAFETY IN OFFSHORE OPERATIONS) RULES, 2006.

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